- 36 - assertion that security expenses were 96 to 97 percent business in nature and only 3 to 4 percent personal is likewise in direct conflict with the respective charges shown for the Foothill Drive and 24th Street properties in the proffered invoices. Thus, what testimony was offered concerning the proportion of security costs attributable to the residence has proven unreliable. Nor have petitioners suggested grounds on which any particular expenses disallowed as potentially residential should not be subject to the proscriptions of section 280A. Regarding costs for security while traveling, Mr. Deihl testified that guards secured merchandise at conventions but also protected family members, particularly children, by acting as a buffer between them and the distributors and by escorting them amongst the various rooms, etc. Petitioners’ sole and entire argument on brief addressing security is as follows: “we find that Respondent disallowed almost $12,000 in security expense with respect to security guards during a trip to Puerto Rico in February of 1998 for Petitioners’ training. Petitioners testified about the need for security during their business trips.” The referenced outlay is evidenced by an invoice from Michael Reed dated February 18, 1998, showing three charges. The first is $8,646 for 752 hours, at the stated rate of $11.50 per hour, on 2/8/98 through 2/21/98, at the location “POST 1”. NextPage: Previous 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 Next
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